COCONUT ANIMATED ISLAND LIMITED v THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS [2024] UKUT 00075 (TCC)
| Jurisdiction | UK Non-devolved |
| Judge | Judge Greg Sinfield,Ashley Greenbank |
| Court | Upper Tribunal (Tax and Chancery Chamber) |
| Published date | 25 March 2024 |
Neutral Citation: [2024] UKUT 00075 (TCC) Case Number: UT/2022/000123
UPPER TRIBUNAL
(Tax and Chancery Chamber) Rolls Building, Fetter Lane,
London, EC4A 1NL
SEED ENTERPRISE INVESTMENT SCHEME – whether arrangements for issuing shares
were “disqualifying arrangements” – whether Condition A in s257CF(3) Income Tax Act 2007
met – scope of “arrangements” in s257HJ – meaning of “relevant person” and “party to the
arrangements” in s257CF(6)
Heard on: 16 October 2023
Judgment date: 25 March 2024
Before
JUDGE GREG SINFIELD
JUDGE ASHLEY GREENBANK
Between
COCONUT ANIMATED ISLAND LIMITED Appellant
and
THE COMMISSIONERS FOR HIS MAJESTY’S REVENUE AND CUSTOMS
Respondents
Representation:
For the Appellant: Harriet Brown, counsel, and Rebecca Sheldon, counsel, instructed by
the Appellant
For the Respondents: Ruth Hughes, counsel, and Tomos Rees, counsel, instructed by the
Solicitor’s Office to His Majesty’s Revenue and Customs
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